On 29 January 2026, the UK Office of Financial Sanctions Implementation (OFSI) published its response to the recent consultation on reforming its enforcement process. The reforms, prompted by the increased volume and...more
On 26 January 2026, the United Kingdom’s Office of Financial Sanctions Implementation (OFSI) published a penalty notice regarding a breach of UK financial sanctions by the Bank of Scotland Plc (Bank of Scotland). ...more
2/11/2026
/ Breach of Financial Sanctions ,
Economic Sanctions ,
Enforcement Actions ,
Financial Institutions ,
Financial Services Industry ,
Financial Transactions ,
Lloyds Banking Group ,
Office of Financial Sanctions Implementation (OFSI) ,
Penalties ,
Politically Exposed Person (PEPs) ,
Royal Bank of Scotland ,
Russia ,
UK
On 11 November 2025, the Financial Conduct Authority (FCA) shared its findings following its review of risk assessment processes and controls in firms subject to its regulation. The FCA’s review considered both business-wide...more
On 26 November 2025, the Serious Fraud Office (SFO) published its Updated Guidance on how it would evaluate a company’s compliance programme (the Guidance) for the purposes of prosecutions, considering defences to the...more
On 23 October 2025, the Council of the European Union announced the 19th EU package of sanctions against Russia, reflecting the continued commitment of the European Union to respond to the ongoing conflict in Ukraine and to...more
11/13/2025
/ Banking Sector ,
Belarus ,
Cryptocurrency ,
Economic Sanctions ,
Energy Sector ,
EU ,
International Trade ,
Natural Gas ,
Oil & Gas ,
Popular ,
Russia
The Crown Prosecution Service (CPS) and the Serious Fraud Office (SFO) have jointly updated their Corporate Prosecutions Guidance (the Guidance), providing clarification on their expectations for organisations in relation to...more
We discussed in an earlier blog that the United Kingdom’s Financial Conduct Authority has axed proposed “name and shame” rules, retaining only an ability to make a public announcement about an investigation in “exceptional...more
On 18 July 2025, the Council of the European Union adopted additional measures which have been introduced in its 18th sanctions package in response to the ongoing conflict in Ukraine (the Package)....more
On 21 July 2025, the UK Office for Financial Sanctions Implementation (OFSI) published its latest sector-specific threat assessment focusing on UK crypto-asset firms’ exposure to financial sanctions breaches, covering...more
8/4/2025
/ Anti-Money Laundering ,
Blockchain ,
Cryptoassets ,
Cryptocurrency ,
Digital Assets ,
Economic Sanctions ,
Financial Conduct Authority (FCA) ,
FinTech ,
Office of Financial Sanctions Implementation (OFSI) ,
Reporting Requirements ,
Risk Management ,
UK
On 22 July 2025, the UK’s Office of Financial Sanctions Implementation (OFSI) launched a major consultation proposing wide-ranging enhancements to its civil enforcement framework (the Consultation). The Consultation is open...more
On 14 July 2025, the United Kingdom’s Foreign, Commonwealth and Development Office released important sanctions guidance aimed specifically at non-UK companies operating outside the United Kingdom, with a special focus on...more
On 18 June 2025, the UK Office for Financial Sanctions Implementation (OFSI) released a Threat Assessment (the Assessment) targeting Art Market Participants (AMPs) and High-Value Dealers (HVDs). This follows new rules from 14...more
7/23/2025
/ AML/CFT ,
Anti-Money Laundering ,
Art ,
Due Diligence ,
Economic Sanctions ,
Financial Crimes ,
Fine Art ,
Office of Financial Sanctions Implementation (OFSI) ,
Reporting Requirements ,
Risk Management ,
UK
On 2 July 2025, the United Kingdom (UK) Financial Conduct Authority (FCA) published a Consultation Paper and Policy Statement (CP25/18) on tackling non-financial misconduct in financial services....more
The United Kingdom’s Foreign, Commonwealth and Development Office has published guidance on United Kingdom’s Russia sanctions compliance for non-UK businesses operating outside the United Kingdom (the Guidance). It also...more
On 18 June 2025, the UK Office for Financial Sanctions Implementation (OFSI) published a threat assessment (the Assessment) on compliance with UK sanctions and money laundering law for art market participants (AMPs) and high...more
7/15/2025
/ AML/CFT ,
Anti-Money Laundering ,
Art ,
Beneficial Owner ,
Digital Assets ,
Due Diligence ,
Economic Sanctions ,
Money Laundering ,
Office of Financial Sanctions Implementation (OFSI) ,
Penalties ,
Reporting Requirements ,
Risk Assessment
Following a two-part consultation, which began in February 2024 (i.e., CP 24/2 and CP 24/2: Part 2) and was accompanied by a Policy Statement (PS25/5) setting out the UK Financial Conduct Authority’s (FCA) consultation...more
On 15 May 2025, the UK government published a policy paper summarising findings from a cross-government review of sanctions implementation and enforcement. The Foreign, Commonwealth and Development Office led the review in...more
On 8 May 2025, the United Kingdom’s Office of Financial Sanctions Implementation (OFSI) of HM Treasury published a penalty notice regarding a breach of financial sanctions by a UK registered company—Svarog Shipping & Trading...more
5/30/2025
/ Compliance ,
Economic Sanctions ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
Government Agencies ,
Office of Financial Sanctions Implementation (OFSI) ,
Penalties ,
Reporting Requirements ,
Request For Information ,
UK
In a bid to further increase the pressure on Russia, the Council of the European Union has adopted additional measures which have been introduced in its 16th sanctions package. The new measures amending the framework Council...more
The United Kingdom’s Serious Fraud Office (SFO) recently published updated guidance on how corporates can best avoid or reduce the risk of prosecution in cases involving economic crimes such as bribery, fraud and corruption...more
The United Kingdom’s Office of Financial Sanctions Implementation (OFSI) has published a report detailing suspected breaches of UK financial sanctions involving UK property and related services firms since February 2022 and...more
4/28/2025
/ Anti-Money Laundering ,
Beneficial Owner ,
Economic Sanctions ,
Landlords ,
Money Laundering ,
Office of Financial Sanctions Implementation (OFSI) ,
Property Owners ,
Real Estate Transactions ,
Reporting Requirements ,
Suspicious Activity Reports (SARs) ,
UK
In its first-ever threat assessment of the UK legal sector, the UK’s Office of Financial Sanctions Implementation (OFSI) has raised red flags with regards to suspected sanctions breaches involving UK legal services providers...more
The UK’s Financial Conduct Authority had proposed a so-called “name and shame” approach that would have allowed it, subject to certain safeguards, to disclose its investigations into firms publicly at an early stage (see our...more
The United Kingdom’s Financial Conduct Authority (FCA) has announced significant changes to its regulatory approach, including dropping the obligation to “name and shame” firms under investigation, dropping the proposed...more
On 13 February 2025, the Office of Financial Sanctions Implementation (OFSI) published its assessment of suspected sanctions breaches involving financial services firms since February 2022 (the Assessment). The Assessment...more